ACA Code C.3.b: The Testimonial Rule Every Counselor Should Know

If you’re a Licensed Professional Counselor or Licensed Mental Health Counselor, the code that governs your practice is the American Counseling Association’s, not psychology’s or social work’s. Most explainers about therapist reviews treat all three professions as if they say the same thing. They don’t. Our overview of all three codes covers the broad strokes across APA, ACA, and NASW. This guide goes deep on the one that actually applies to LPCs and LMHCs.

Most summaries of C.3.b stop at the first sentence: no soliciting testimonials from current or former clients. That’s true, but it’s half the rule. The second sentence is where ACA actually diverges from psychology’s and social work’s codes, and it’s the part almost nobody quotes.

What C.3.b Actually Says

Here is the full text of ACA Code C.3.b, word for word, from the 2014 ACA Code of Ethics: “Counselors who use testimonials do not solicit them from current clients, former clients, or any other persons who may be vulnerable to undue influence. Counselors discuss with clients the implications of and obtain permission for the use of any testimonial.”

That’s two rules packed into two sentences. The first is a solicitation ban: you cannot ask a current client, a former client, or anyone vulnerable to undue influence for a testimonial. Full stop, no exceptions. The second is a use rule: before you use any testimonial, solicited or not, you discuss what publishing it means with the client and get their permission.

Read together, the two sentences separate the act of asking from the act of using. ACA never says a counselor can’t publish an unsolicited testimonial. It says you can’t ask for one, and if you do use one, permission and disclosure come first, straight from Standard C.3.b of the 2014 ACA Code of Ethics.

Why ACA Differs From APA and NASW Here

The American Psychological Association’s parallel rule, Ethics Code 5.05, is a single sentence: “Psychologists do not solicit testimonials from current therapy clients/patients or other persons who because of their particular circumstances are vulnerable to undue influence.” There’s no second sentence. APA never addresses what happens when a client volunteers a testimonial without being asked.

The National Association of Social Workers goes the opposite direction. Code 4.07(b) reads: “Social workers should not engage in solicitation of testimonial endorsements (including solicitation of consent to use a client’s prior statement as a testimonial endorsement) from current clients or from other people who, because of their particular circumstances, are vulnerable to undue influence.” Notice the parenthetical. NASW doesn’t just ban asking for a testimonial. It bans asking permission to use one a client already handed you unprompted.

Three codes, three different answers to the same question: can a counselor publish a testimonial a client left without being asked? ACA says yes, with permission and disclosure first. NASW says the consent conversation itself is off-limits. APA never says either way, which most ethics consultants read as a closed door by omission.

Who Counts as “Vulnerable to Undue Influence”

Current clients are the obvious case. The standard reaches further than that, and knowing where it stops is where most counselors get tripped up.

Group therapy members are a common blind spot. Most ethics consultants treat someone in one of your process groups as a current client for C.3.b purposes, even though the relationship looks different from individual therapy. The same reasoning is often extended to supervisees and students in an ongoing evaluative relationship with you, where their standing or licensure hours depend on your assessment. The Code itself doesn’t name these categories. It defines the standard by the power dynamic, “vulnerable to undue influence,” and leaves the specific relationships to professional judgment.

“Vulnerable to undue influence” is deliberately broad language, not a fixed list of relationship types. That’s a feature, not a gap. It asks you to reason from the power dynamic itself rather than checking a box for “client” versus “not client.”

What “Discuss Implications and Obtain Permission” Requires in Practice

The Code doesn’t hand counselors a script for this conversation, but the two verbs tell you what has to happen before a testimonial goes on your website. “Discuss the implications” means the client understands what publishing does. It’s public, it’s likely permanent once cached or screenshotted somewhere, and it may signal to others that they’re in treatment with you. “Obtain permission” means something more specific than silence or an implied yes.

Get it in writing. A short release form covers you here. State what will be published, where it will appear, and for how long. Note that the client can ask you to remove it later, and follow through if they do. Keep the signed form in the client’s file, the same way you’d keep any other authorization for release of information.

The Practical Alternative: Colleague Testimonials, Not Client Ones

The lowest-risk testimonial on your website isn’t from a client at all. A colleague, or someone who took a one-off continuing-education workshop you taught, can usually speak to your clinical skill without triggering C.3.b. The distinction that matters is ongoing evaluative power. A workshop attendee’s license or livelihood doesn’t depend on you, while a current supervisee or student in an ongoing training relationship with you does, which is why that group stays on the vulnerable side of the line.

This isn’t a loophole. It’s the Code working as intended. The rule exists to keep a power imbalance from turning into marketing material. Remove the power imbalance and the concern disappears with it. If your site currently leans on client praise to build trust, our guide on building trust without client testimonials covers the other levers that work just as well.

Handling Unsolicited Reviews

Say a former client, months after termination, leaves you an unprompted five-star Google review describing exactly how helpful you were. You didn’t ask for it. Can you use it?

Not automatically. The second sentence of C.3.b still applies. Use requires discussing implications and getting permission, even when the review showed up on its own. Reach out, have the conversation, and get it in writing before you screenshot that review onto your homepage.

If you’d rather not reach out at all, or you can’t reach the client, leave the review exactly where it is. Don’t reply to it. A public reply confirms a clinical relationship, which is its own confidentiality problem, separate from C.3.b entirely. For more on the mechanics of building a review presence without crossing that line, see our guide on getting Google reviews for your therapy practice ethically.

Post a short, standing statement on your Google Business Profile or website explaining why you don’t respond to reviews. Rob Reinhardt’s Counseling Today piece on this topic recommends language like “we are unable to respond to any review, positive or negative,” paired with an invitation to reach out directly instead of posting publicly.

If a client does post and you’re worried about identifying details, ask them privately to use a pseudonym or soften specifics. You can’t control what someone writes about you, but you can ask.

What Happens If You Get This Wrong

A C.3.b violation isn’t usually the kind of thing that ends a career on its own, but it is the kind of thing that surfaces in a board complaint alongside other, more serious allegations. Once a complaint is open, investigators look at everything on your public-facing materials, and a solicited testimonial with no permission on file is an easy, documentable finding.

The more common cost isn’t a formal complaint at all. It’s the testimonial becoming evidence in a dispute you never saw coming, a custody matter, a workplace conflict, anything where a client’s public praise of their therapist gets pulled into an unrelated proceeding. Written permission and a clear record of the conversation are what protect you if that happens.

Frequently Asked Questions

Sources and References

The ethics codes cited in this guide are primary sources, publicly available from each governing body, and were verified directly against their published text before publication. This guide summarizes and interprets the relevant provisions; it is not legal or professional ethics advice. For guidance specific to your license and jurisdiction, consult a professional ethics consultant or your licensing board.